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divorce proceeding against Longina Newsom indicating that he and
Longina Newsom did not separate until approximately March 14,
1998. On the basis of the foregoing evidence, we conclude that
petitioner has not established that he and Longina Newsom
maintained separate households throughout the last 6 months of
1997.
While such a finding is sufficient to determine that
petitioner does not qualify as a head of household, see sec.
7703(b)(3), petitioner does not qualify on additional grounds.
Even if we were to find, on the basis of petitioner and Longina
Newsom's testimony, that Krissa Williams resided with petitioner
for more than one-half of the year at issue, petitioner failed to
establish that he provided more than one-half the cost of
maintaining his household as the principal residence of Krissa
Williams during 1997.
The regulations provide guidance concerning the types of
expenses which constitute the cost of maintaining a household.
These expenses include "property taxes, mortgage interest, rent,
utility charges, upkeep and repairs, property insurance, and food
consumed on the premises." Sec. 1.7703-1(b)(4), Income Tax Regs.
Petitioner offered no evidence that he incurred these types of
expenses in maintaining the households in which he alleges he and
Krissa Williams lived.
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